Denmark and Greenland have signed an amending protocol to update the Denmark-Greenland Income Tax and Mutual Assistance Treaty (1979).
The announcement was made by the Danish Ministry of Taxation on 20 August 2024
The new protocol incorporates the DBO of the OECD’s BEPS minimum standards (Base Erosion and Profit Shifting), which Denmark and Greenland are obliged to implement; introduces a provision not to impose withholding tax on dividends to recognised pension institutions or to banking institutions’ pool schemes; and inserts a renegotiation clause for taxation of dividends in the event of significant changes to Greenland’s corporate tax legislation.
The protocol shall become effective following the exchange of ratification instruments. The bill is expected to be presented in November 2024 with a view to the agreement entering into force on 1 January 2025.
The treaty has been previously amended by protocols in 1983, 1986, 1990, 1995, 1997, 1998, 2000, 2004, and 2012. The latest signing took place during a visit by Jeppe Bruus Christensen, Danish Minister of Taxation, to Greenland from 18 to 21 August 2024.
